## Facts

- Maryland juvenile proceedings under Rule 911 used “masters” to conduct hearings and issue proposed findings and recommendations to a juvenile court judge.
- A master’s proposed finding (including nondelinquency) was not a final adjudication; the judge could accept, modify, or reject the master’s proposals.
- The State could file “exceptions” to a master’s proposed findings, triggering review by the judge based on the record made before the master.
- The judge could receive additional evidence only if the parties did not object; otherwise, the record remained closed.
- A class of juveniles sued Maryland officials under 42 U.S.C. § 1983, seeking to stop the State from filing exceptions to proposed nondelinquency findings (and dispositions) on Double Jeopardy grounds.
- The federal district court held that jeopardy attached at the master’s hearing and that State-filed exceptions subjected juveniles to a second jeopardy; it enjoined the State from taking exceptions.
- Maryland officials appealed directly to the U.S. Supreme Court.

## Issues

1. Whether the Double Jeopardy Clause prohibits the State from filing exceptions to a juvenile master’s proposed finding of nondelinquency, followed by judicial review under Maryland Rule 911.
2. Whether Rule 911 creates two successive adjudications (a second “trial”) or a single continuous adjudicatory proceeding culminating in one final judgment by a judge.

## Decision

- The Supreme Court reversed the district court’s judgment and vacated the injunction.
- The Court held, 6–3, that the Double Jeopardy Clause does not bar the State from taking exceptions to a master’s proposed findings under Rule 911.
- The Court characterized the master’s hearing and the judge’s action on exceptions as parts of one unitary proceeding that ends in a single adjudication by the judge.
- The Court concluded the procedure did not give the prosecution an impermissible second opportunity to present its case because the evidentiary record is ordinarily closed after the master’s hearing unless the juvenile consents to additional evidence.

## Legal Principles

- A multi-stage juvenile process may be treated as a single proceeding for double jeopardy purposes when a master’s findings are only recommendations and a judge makes the sole binding adjudication.
- Double jeopardy concerns about repeated attempts to convict are reduced where the State ordinarily does not receive a second evidentiary presentation and judicial review proceeds on the existing record.
- Jeopardy is not treated as culminating in a final adjudication at the master stage when the master lacks authority to enter a final order and the judge is the exclusive adjudicator.
- A procedure that continues the original adjudication to final judgment, without imposing a second full trial, does not constitute a second jeopardy merely because it includes internal review of a recommendation.

## Conclusion

Maryland’s Rule 911 exception process does not violate the Double Jeopardy Clause because the master’s hearing is an advisory step within a single juvenile adjudication, and the judge alone renders the final, binding decision, typically on a closed record that prevents a second evidentiary attempt by the State without the juvenile’s consent.


Swisher v. Brady, 438 U.S. 204 (1978)